Luxembourg RCS: New Digital Procedures and Identification Requirements Starting November 2024

As of 12 November 2024, the Luxembourg Trade and Companies Register (“RCS”) will implement several procedural changes aimed at simplifying administrative processes and enhancing the accuracy of recorded information. These updates include transitioning requisition forms from PDF format to an interactive HTML format, allowing users to complete them directly online. This technological update, which removes certain practical constraints associated with PDF forms, will also create a more user-friendly interface. Furthermore, it restricts the ability to forward completed forms to third parties, ensuring that only the applicant may submit them.

In an effort to improve data transparency and security, a new identification requirement is being introduced: all individuals registered with the RCS must now provide a Luxembourg National Identification Number (“NINL”). This measure, aligned with Article 12bis of the amended Law of 19 December 2002, on the Trade and Companies Register, applies to every individual associated with a registered corporate entity, including company representatives (e.g., managers and directors), shareholders, and other involved natural persons.

The new requirements apply immediately to all new registrations. For individuals already registered, updating their information—particularly the provision of their NINL—will be voluntary at first but will later become mandatory (with a date still to be determined).

If a registered individual already has a Luxembourg NINL (typically the matriculation number issued by the Luxembourg Social Security Authority (CCSS)), they will only need to provide it by completing the relevant online form, without the need to submit supporting documents. However, for those without an NINL, a process will be in place to generate this number upon registration, requiring additional information, such as nationality and private residential address, accompanied by supporting documents (e.g., ID card, proof of residence).

Additionally, the RCS is introducing automatic verification of Luxembourg addresses entered in its database, based on the national register of localities and streets. When an address is entered in the form, it will be automatically checked for consistency with official data from the localities register. If there is a discrepancy, an error message will prompt the applicant to correct the information before proceeding. This measure aims to prevent address errors and ensure that geographical information recorded at the RCS is accurate and up-to-date.

These adjustments are designed to facilitate administrative processes, strengthen data security and compliance, and improve the reliability of personal information recorded in Luxembourg, thereby meeting the demands of a more secure and modern administrative framework.

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